The Food and Nutrition Service of the United States Department of Agriculture (USDA) (defendant) published for comment a rule proposing a maximum sugar content for cereals authorized for use in the federally funded Special Supplemental Food Program for Women, Infants, and Children (WIC). Under WIC, the USDA designs food packages to reflect the different nutritional needs of women, infants, and children. The agency provides grants to state or local agencies to distribute cash or vouchers to WIC participants in accordance with USDA regulations regarding type and quantity of food. In addition to the proposed rule, the USDA published a preamble, in which it discussed the general purpose of the rule and the problems associated with high sugar foods. Neither the proposed rule nor its preamble discussed sugar in relation to flavoring milk, though the rule did include flavored milk in the list of approved food packages for women and children without special dietary needs. In response to public comments, the USDA’s final rule deleted flavored milk from the list of approved food packages for women and children. The Chocolate Manufacturers Association (CMA) (plaintiff) sought relief from the rule in federal district court, arguing (1) that the USDA did not provide notice that the disallowance of flavored milk would be considered; and (2) that the USDA gave no reasoned justification for changing its position about the nutritional value of chocolate in the food distributed under its authority. The district court denied CMA’s request for relief, and CMA appealed.